17SL-CC00133
IN THE CIRCUIT COURT OF ST. LOUIS COUNTY, MISSOURI g
218T JUDICIAL CIRCUIT 2
KEITH WILDHABER, ) 7
Plaintiff, } 9
a } CaseNo. 7
SAINT LOUIS COUNTY, MISSOURI, : Division/Judge é
Serve: 4 8, Central Avenue ) z
Clayton MO 63105 ) JURY TRIAL DEMANDED 2
Defendant. ; 8
3
PETXIION 3
2
=
COMES NOW Plaintiff Keith Wildhaber (“Plaintiff”), by and through his undersigned
counsel, and for his Petition against Defendant Saint Louis County, Missouri (hereinafter
“Defendant” or “the County”), states as follows:
INTRODUCTION
1, This lawsuit is being brought by Plaintiff to seek redress for unlawful employment
discrimination and retaliation. Plaintiff has worked as a police officer for Defendant Saint Louis
County ftom May 1994 to the present. Because of his gender/sex, Plaintiff has been subjected
to—and continues to be subjected to—unlawful employment discrimination by being denied
multiple promotions. Defendant's actions in denying Plaintiff multiple promotion opportun
for which he was qualified amount to a violation of the Missouri Human Rights Act (“MHRA”).
Further, Defendant has retaliated against Plaintiff for engaging in activity thet is legally protected
by the MERA.
PARTIES
a Plaintiff is an adult male resident of the State of Missouri.3. Defendant Saint Louis County, Missouri is a political subdivision of the State of
Missouri, exists by reason of the Constitution and Laws of the State of Missouri, and acts under
the color of State law.
JURISDICTION AND VENUE
4, Venue is proper in this Court because, upon information and belief, Plaintiff's
employment with Defendant during times relevant occurred within St, Louis County, Missouri,
and because the actions/events that gave rise to this Petition oceurred within St. Louis County,
Missouri, This Court maintains jurisdiction and venue over Plaintiffs claims brought herein
pursuant to R.S.Mo. § 213,111 and/or § 508.010.
GENE) UI
Plaintiff's Employment Background with the County’s Police Department
5. Plaintiff was hired by the St. Louis County Police Department as a Security Officer
in May 1994, following a four-year stint in the U.S. Army.
6. In July 1997, Plaintiff was selected as a candidate for the St. Louis County Police
Academy.
7. In December 1997, Plaintiff graduated from the St. Louis County Police Academy
and was awarded his commission as a St. Louis County Police Officer.
8. In December 1997, Plaintiff began working as a Patrolman in the Affton Precinct.
9. In January 2006, Plaintiff transferred to the Detective Bureau and worked white
collar investigations until July 2011.
10. In July 2011, Plaintift was promoted to the rank of Sergeant.
U1, From July 28, 2011 until May 2016, Plaintiff was assigned to and worked out of
the Affton Precinct,
Wel €€:20- L102 “OF Alenuer - Sjunog sino7 Ig - pe Aveauonaar12, The Affton Precinct was a desirable work location for Plaintiff, primarily because
itis convenient and located close to Plaintiff's home in Oakville, Missouri.
13. From January $,2016, until May 2016, Plaintiff worked on the afternoon shift (pm
to I pm) out of the Affton Precinct.
14. Throughout his employment with the County, Plaintiff has received extremely
Positive feedback about his work performance, His written performance reviews consistently
reflect that his performance “exceeds standards” or is “superior” in all rated categories.
nti omotion to Lieutenant
15, In approximately 2014, not long after Jon Belmar became the County Police Chief,
the County Police Department announced a new promotional process to fill positions for the rank
of Lieutenant.
16. In approximately February 2014, Plaintiff first applied for a Lieutenant position.
17. Based on the criteria identified for the position, Plaintiff was qualified to apply for
the position of Lieutenant.
18. Plaintiff took a witten test and underwent an assessment, as did other candidates.
19. Plaintiff's scores in that promotional process ranked him #3 out of 26 total
candidates.
20. Per the County's policy/practice, the candidates were divided into three groups:
‘A,B, and C. The individuals in the A group are considered to be first in line for promotions, while
individuals in the B and C groups generally are not considered for promotions, unless all of the
individuals from the A group have been promoted,
21, Part of Plaintif’s duties as « Sergeant included checking on local restaurants in the
evening as a safety precaution,
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